Interpretation ID: 86-1.8

TYPE: INTERPRETATION-NHTSA

DATE: 01/13/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Robert R. Gregg

TITLE: FMVSS INTERPRETATION

TEXT:

January 13, 1986 Mr. Robert R. Gregg Metzeler Motorcycle Tire Agent Gregg, Inc. 144 Railroad Avenue Suite 215 Edmonds, WA 98020 Dear Mr. Gregg: This responds to your letter to Steve Kratzke of my staff, seeking an interpretation of Standard No. 119, New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars (49 CFR Part 571.119). Specifically, you asked if a motorcycle could have its maximum load capacity labeled on the sidewall as follows: At 60 MPH Max load lbs. at psi cold. Such labeling would violate Standard No. 119, as explained below. Section S6.5 of Standard No. 119 requires that certain information be labeled on the sidewall of all tires to which the standard applies. Section S6.5(d) requires the maximum load rating and corresponding inflation pressure to appear on all motorcycle tires as follows: Max load lbs at psi cold. No speed rating or restriction may be given in conjunction with the maximum load rating on the sidewall of the tire. That rating, as its name implies, is intended to alert consumers to the tire's maximum capabilities. A manufacturer may label a speed restriction on its tires to alert consumers to the tire's maximum speed if that maximum is 55 miles per hour (mph) or less. Section S6.5(e) permits speed restrictions of 55 mph or less to be labeled on the sidewall of the tire as follows: Max speed mph. However, this provision of Standard No. 119 would not allow you to assign a speed restriction of 60 mph to these motorcycle tires. First, no speed restriction in excess of 55mph may be assigned to any tires; see Table III in Standard No. 119. Second, all motorcycle tires are subject to the high speed test, regardless of any speed restrictions; see S6.3 of Standard No. 119. During the high speed test, the tire is subjected to speeds up to and including 85 mph. Parenthetically, I should add that even if speed restrictions of more than 55 mph were allowed, this particular tire would not be a candidate for a speed restriction of 60 mph. You stated in your letter that these tires actually are assigned an H speed rating. Under the speed rating system used in Europe, an H speed rating on a motorcycle tire means the tire is capable of being used at speeds up to 130 mph. Assuming you have used the speed rating accurately, there is no basis for implying that these tires are not capable of speeds greater than 60 mph.

As stated above, the purpose of the maximum load ratings is to alert consumers to the tire's maximum capabilities. The agency knows that the maximum load that can safely be carried by a tire varies with the speed at which the tire is driven. Allowing tire manufacturers to specify a maximum load based on an artificial speed restriction of 60 mph would result in the tires being overloaded if the consumer were to exceed 60 mph. Overloaded tires are substantially more likely to experience a tire failure than properly loaded tires. Since the purpose of the labeling requirements in Standard No. 119 is to provide consumers with technical information necessary for the safe operation of the tires, the standard does not permit tire manufacturers to provide information that will result in the tires being overloaded whenever an artificial speed restriction is exceeded. If you have any further questions or need more information in this area, please contact Mr. Kratzke at this address or by telephone at (202) 426-2992. Sincerely, Original Signed By Erika Z. Jones Chief Counsel